Add to the first paragraph – it is between non-VRS deaf employee and hearing persons.

I don’t mind sharing what probably should be considered proprietary info: Convo processed .003 of conference calls by Convo staff; and rest of conference calls – 6% of all Convo calls – were done by deaf outside of Convo. Keep in mind ALL of these conference calls involved hearing persons (two or more hearing persons). These were not allowed by the NECA/FCC for reimbursement.

eyes open & thumbs up…

One slight correction: FCC is giving directives to the NECA to hold back lot of conference calls that were between deaf AND hearing persons.

On ur playing devil’s advocate: as matter of fact, I believe one VRS provider idea is one of the items that the FCC is considering. Incentive and new features would be minimized big time. Something I have observed the difference between RFP and competitive market. With RFP, new features only happen with new proposals while with competitive market new features and innovations constantly are happening.

Ah, competition is mentioned in Title IV – just not the word. If you read Title IV carefully, it prefers that ALL telephone companies of state provide relay service – in that itself is obviously competitive. That’s the first choice. Then as if after-thought it allows alternatives which is what all but one state adopted; via RFP – one provider. It is interesting how this works out.

For you historical buffs, a few states opted not to release RFP – what happened? State Telephone Association would release RFP – usually one to several pages (average RFP from most state gov’t is about 75 to 100 pages) so state association can choose one instead of having all telephone companies provide relay service.

eyes open & thumbs up..

Playing devil’s advocate here: as you know that the ADA’s public interest with TRS is to ensure that the deaf are able to access the telecommunication networks, would it be entirely justifiable for the FCC to decide that to make things efficient (which is an ADA mandate), only there will be only one provider? Since one company can do it a lot cheaper than everyone else, so what would be the point of ‘wasting’ $ on VRS providers without high call volumes?

As you know, the FCC can completely rewrite its regulations as long as it justifies its decisions via the Administrative Procedures Act. Title IV only has a few statutory requirements (confidentiality, efficient, etc.) and the rest are just regulations from the FCC. FCC’s responsibility is to ensure that the deaf are able to access the telecommunication networks–exactly how that would be done would be completely at their discretion. In fact, competition is not mentioned at all in Title IV.

Of course, I’m playing devil’s advocate with a lot of hypotheticals, and this certainly won’t happen, but I’m just saying that the FCC has a lot of leeway here in terms of what to do, as long as its justifications are reasonable.

On a serious note, the very fact that the employer provided an 800 number for its deaf employees to use for work purposes clearly makes this a Title I issue.

But again, FCC is only prohibiting conference calls where there are NO HEARING PEOPLE involved at all. As I understand, the FCC will reimburse for any conference calls that involves at least one non-VRS user.

Try this link:

http://fjallfoss.fcc.gov/ecfs/document/view?id=6520221125

eyes open & thumbs up…

Would it be possible for you to post the ex parte letter you just sent to FCC regarding the VRS costs on the Ed’s Alert website?

Very good questions. It is probably reason why I am not an accountant. That was my “educated” guess.

Managing a VRS is lot more complicated. For example, to run a call center requires horde of equipment, technical platform, high speed internet to support number of stations (video interpreters), etc. of all which can exceed a million dollars. To say nothing of the administration people who are needed to monitor various aspects of VRS. Let’s not forget marketing and sales work.

It is reason why I said salary plus overhead costs for reimbursement of VRS conference calls by VRS staff. Salaries of video interpreters varies a lot. My guess of the national average is probably around $35 an hour. 35 divided by 60 = .59 so about 60 cents per min. Let’s not forget the building, equipment, high speed, etc. then to divide them by number of stations would give you approx overhead. So with my wild guess, I would say $2 per min for conference calls made by VRS employee would be reasonable (?).

FCC or NECA are in much better position to calculate that as they know all costs in managing VRS as they receive these vital information from all VRS providers.

Now to help VRS providers make money. Keep in mind that right now only one company has about 80% of the market – we should not look to that company for good reimbursement rate as that company makes money out of high call volume and high call volume is easier to make the system more efficient. The current reimbursement rates probably could stand to be little bit lower, but not much. It really is expensive to run a VRS as I’ve discovered. The tiered rate plan for VRS seems to be a good idea except for a few issues. I have submitted an ex parte letter to the FCC regarding this very issue.

Hope this info will help you better understand the expenses of managing VRS.

eyes open & thumbs up…